The defendant is charged [in count __]
with trafficking in personal identifying information. The statute defining this
offense reads in pertinent part as follows:

a person is guilty of trafficking
in personal identifying information when such person sells, gives or otherwise
transfers personal identifying information of another person to a third person
knowing that such information has been obtained without the authorization of
such other person and that such third person intends to use such information for
an unlawful purpose.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 2 - Not authorizedThe second element is that the
defendant knew that the information had been obtained without the authorization
of the person whose identifying information it was. A person acts "knowingly"
with respect to conduct or circumstances when (he/she) is aware that (his/her)
conduct is of such nature or that such circumstances exist. <See
Knowledge, Instruction 2.3-3.>

Element 3 - For unlawful
purpose
The third element is that the
defendant knew that the third person intended to use the information for
unlawful purposes. An unlawful purpose is anything that is prohibited by law.
<Insert specific allegations.>

Conclusion

In summary, the state must prove
beyond a reasonable doubt that the defendant 1) (sold / gave / transferred)
personal identifying information to another person, 2) (he/she) knew that the
identifying information had been obtained without authorization, and 3) (he/she)
knew that the person to whom the information was transferred intended to use it
for unlawful purposes.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
trafficking in personal identifying information, then you shall find the
defendant guilty. On the other hand, if you unanimously find that the state has
failed to prove beyond a reasonable doubt any of the elements, you shall then
find the defendant not guilty.